https://leader.pubs.asha.org/article.aspx?articleid=2292026Medicare 2012 Home Health Rates Fall 2.3%Medicare reimbursement rates for home health agency (HHA) 60-day episodes will be cut by 2.3% in 2012 rather than by the 3.3% initially proposed (The ASHA Leader, Aug. 30, 2011). The rate is indicated in the final rule issued for the Medicare HHA prospective payment system (PPS) by the Centers ...2011-11-01T00:00:00Bottom LineMark Kander

Medicare reimbursement rates for home health agency (HHA) 60-day episodes will be cut by 2.3% in 2012 rather than by the 3.3% initially proposed (The ASHA Leader, Aug. 30, 2011).

The rate is indicated in the final rule issued for the Medicare HHA prospective payment system (PPS) by the Centers for Medicare and Medicaid Services (CMS). The rule appeared in the Federal Register [PDF, 4.1MB] on Nov. 4.

Some of the fee reductions are based on widespread inaccurate patient health status coding by HHAs between 2000 and 2008. According to estimates by the National Association for Home Care and Hospice, half of all Medicare HHAs will operate at a deficit in 2012.

Payment for speech-language treatment (and occupational and physical therapy) is made in tiered levels of visits in 60-day episodes. Although high-therapy episodes (i.e., more than 20 total therapy visits) have shown high payment-to-cost ratios, episodes with only three to five therapy visits have been underpaid and have been adjusted.

Other variations in payment per episode are based on the number of therapy visits and other factors:

Episode: first, second, or third

Clinical severity: high, medium, or low

Functional severity: high, medium, or low

Fixed Payments

If a home health episode includes fewer than five total home health visits, the PPS payment is replaced by a fixed per-visit payment based on historic per-visit costs by discipline. The 2012 per-visit rates, known as the low-utilization payment adjustments, have been increased by 1.5% to $134.12 for speech-language pathologists, $123.43 for physical therapists, and $124.46 for occupational therapists (geographically adjusted).

Reassessment

The 2012 regulations include clarification on the timing of patient reassessments. The new regulations state clearly that the reassessment schedule is based on the patient’s total number of therapy visits, not on the number of visits by a specific discipline:

“Where more than one discipline of therapy is being provided, the qualified therapist from each discipline must provide all of the therapy services and functionally reassess the patient [in accordance with regulations] during the visit associated with that discipline which is scheduled to occur close to the 14th Medicare-covered therapy visit, but no later than the 13th Medicare-covered therapy visit” [42 CFR 409.44(c)(2)(i)(C)(2)]. Reassessment is also required “close to the 20th Medicare-covered therapy visit, but no later than the 19th Medicare-covered therapy visit” [409.44(c)(2)(i)(D)(2)].

CMS noted that some of the confusion over the requirement was related to whether the visit count includes both covered and non-covered visits. The regulation specifies “Medicare-covered” therapy visits.

In addition, patients must be assessed every 30 days, independent of the 13th and 19th visit requirements. In a recent post, CMS allows one exception to the 30-day reassessment requirement—if there is a suspension of treatment due to the patient’s hospitalization. However, if a physician has ordered a temporary interruption, CMS states in a frequently asked question document [PDF]: “...we would usually expect that the unique clinical condition of the patient would enable the HHA to anticipate that an interruption in therapy may be needed. In such cases, the HHA should ensure that the requirements are met earlier than the end of the 30-day period to ensure the HHA meets the 30-day requirement.”

The Medicare Benefit Policy Manual will be modified to indicate that the 30-day reassessment can be delayed until the patient’s physician orders therapy to continue.

Physician Face-to-Face Rule

The 2011 requirement that the certifying physician have a face-to-face meeting with the patient prior to HHA admission has been modified. Under the 2012 rule, a physician who saw the patient in an acute or post-acute setting may inform the HHA-certifying physician of the patient’s qualifying conditions.